ML20077B770

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Responds to NRC Re Violations Noted in IE Insp Rept 50-285/83-10.Corrective Actions:Shift Supervisors Retrained on Emergency Response Procedures.Generic Implications of Inspector Findings Under Review
ML20077B770
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 05/13/1983
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Seidle W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20077B740 List:
References
LIC-83-122, NUDOCS 8307250428
Download: ML20077B770 (5)


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Omaha Public Power District 1623 Hamey Omaha. Nebraska 68102 402/536 4000 May 13, 1983 LIC-83-122 A4 f e l

Mr. W.

C.

Se id le, Chief

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Reactor Project Branch 2

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Nuclear Regulatory Commission Region IV W

611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Reference:

Docke t No. 50-285

Dear Mr. Seidle:

IE Inspection Report 83-10 Dated May 4, 1983 The subject report identified one violation related to the training of the Fort Calhoun Station shif t supervisors and understanding of their emergency response responsibilities.

Please find attached the District's response to this vio-lation.

Please note that the violation identified a specific train-ing weakness related to emergency preparedness but it could have potential generic implications, specifically in the area of practical factors performance.

The District is con-ducting a review of other training conducted at the Fort Calhoun Station to assess this potential concern.

This re-view will be completed by December 31, 1983 and will ensure all practical factors adequately demonstrate personnel under-standing and efficient performance of critical functions.

l Sin

ely, JE ogt W.

ones oo Divis n Manager Produc ion Operations cng WCJ/TLP:jmm ooQ Attachment ts cc:

Le Boeu f, Lamb, Leiby & MacRae (Dn.cs l

Mr.

L.

A.

Yandell, Senior l

Res ide nt Inspector 45.5124 Employment with Equal Opportunity Male, Female

Attachment IE INSPECTION REPORT 8 3-10 VIOLATION DISTRICT'S PRELIMINARY RESPONSE Based on the results of an NRC inspection conducted during the period of April 18-22, 1983, and in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C), 47 FR 9987, dated March 9, 1982, the following violation was identified:

Inadequate Training of Shif t Supervisors / Emergency Duty Officers in Emergency Response 10 CFR 50.54(g) requires each reactor licensee to im-plement and follow emergency plans that meet the re-quirements of Appendix E to 10 CPR 50.

Appendix E,Section IV.F requires a training program which ensures that employees are familiar with their specific emer-gency duties.

i These requirements are implemented, in part, by Section 5.1 of the Fort Calhoun Station Radiological i

Emergency Response Plan which states, " initial Emer-gency Duty Officer (EDO) training will consist of re-viewing the Emergency Plan, implementing procedures, and communication systems," and Section 2.1.6 of the Fort Calhoun Station Radiological Preparedness Train-ing Manual which states, "the EDO is responsible for recommending protective actions to authorities re-sponsible for offsite actions" and "the EDO shall demonstrate an acceptable level of knowledge by pass-ing a written examination with a minimum score of 80%."

Contrary to the above, two of the four shift super-visors interviewed during the inspection could not adequately describe or perform their responsibilities 1

for recommending offsite protective actions, warnings, and notifications, and one shift supervisor had not de-monstrated an acceptable level of knowledge during a written examination (ungraded) and a practical factors test.

All shift supervisors interviewed experienced difficulty in using the required EPIPs and none of those interviewed were able to locate and use EPIP-EOF-17, " Initiation of Public Warning."

All of the above indicates inadequate training and inability to follow and implement required procedures.

This is Severity Level IV violation.

(Supplement I)

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District Response A.

Corrective Steps Which Have Been Taken and Results Achieved.

Upon being apprised of the inspector's concerns regard-ing the shift supervisors' training, the District took immediate action to ensure that the shif t supervisors were fully knowledgeable on procedures for recommend-ing offsite protective actions.

Each shift supervisor was retrained on the applicable EPIPs prior to resum-ing Emergency Duty Of ficer (EDO) shift responsibili-ties.

This retraining was completed by April 24, 1983.

Other corrective measures taken included:

(1)

A booklet consisting of an emergency plan check-list and job specific EPIPs has been prepared, using suggestions from control room personnel re-sponsible for performance of these procedures.

The intent of this booklet is to aid the re-sponsible shift supervisors' understanding, re-call, and implementation of the Emergency Plan requirements.

The shift supervisors were pro-vided the appropriate booklet by April 29, 1983.

(2)

EPIP-EOF-17, " Initiation of Public Warning", was included in the booklet described in (1) above, and all shif t supervisors have been trained on the procedure.

This training was completed by April 29, 1983.

(3)

Revision 2 to EPIP-OSC-1, " Emergency Classifi-cation", was issued April 26, 1983 and Revision 6 to EPIP-OSC-2, " Emergency Plan Activa tion",

was issued April 29, 1983.

The revision to EPIP-OSC-2 was initiated prior to the inspection to improve the emergency response personnel's abili-ty to classify accidents by incorporation of a flow sheet methodology.

The revision to EPIP-OSC-2 was implemdnted to facilitate the shift supervisors' ability to classify emergencies, initiate notification, and implement response actions.

(4)

Draft revisions to instructions for the use of communication equipment to include the recently installed conference operations network were available at the Fort Calhoun Station for use by the shift supervisors by April 22, 1983.

These

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revisions to EPIP-TSC-2, " Technical Support Center Communications", and EPIP-EOF-2, "Emer-gency Operations Facility Communication", have been prepared and approved.

Incorporation into official controlled copies is in progress and will be completed by May 13, 1983.

This action improves the shif t supervisors" ability to initi-ate notification and implement response actions.

Full distribution of these procedures will be completed by May 31, 1983.

(5)

The emergency plan training program has been re-viewed to ensure that all EPIPs are covered in the lesson plans.

This review was completed by May 13, 1983.

The actions implemented above have resulted in pro-viding additional assurance that the procedures referenced in the violation can be implemented in a timely manner.

B.

Corrective Steps Which Will Be Taken.

The District has initiated the following actions:

(1)

The need for booklets with duty specific check-lists and pertinent procedures is being evalu-ated for emergency response personnel other than shift supervisors.

(2)

The annual review of EPIPs has been accelerated with emphasis placed on improved human engineer-ing principles.

EPIP format and organization is also being reviewed to determine need for im-provements to aid responcible personnel in the implementation and understanding of these pro-cedures.

This review will be completed by December 31, 1983.

(3)

The District is conducting oral examination 0 and/or walk-throughs for all EDO's, technicians, and monitor team members who have immediate emergency response functions.

These examin-ations/ walk-throughs will be completed by June 1, 1983.

The results of this additional 1

training will identify any deficiencies in the training provided in the past and will be used to improve future training in any identified weak areas.

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, (4)

The District is also in the process of reviewing the emergency plan training program to assess the generic implications of the inspector's find-ings, with special emphasis on improvements on the practical factors requirements.

This review will be completed by December 31, 1983.

(5)

Plans are being developed to emphasize the use of mini-drills as a tool for improving emergency response preparedness.

These mini-drills will be conducted throughout the remainder of this year.

C.

Date When Full Compliance Will Be Achieved.

The District is presently in full compliance regarding the shif t supervisors' capabilities to implement the Fort Calhoun Station Radiological Emergency Response Plan.

The District believes the shif t supervisors, with assistance by augmentation personnel including management representatives, have always had the ability to implement essential emergency responses if necessary.

However, the District also agrees that the shift supervisors' training and knowledge of these actions needed to be upgraded.

Some improvements have been accomplished and additional measures will be taken to ensure a very high level of emergency response proficiency is maintained.

The District is also reviewing the generic impli-cations regarding the practical factors portion of other training conducted at the Fort Calhoun Station.

A schedule will be developed for completing this re-view and any resulting improvements will be imple-mented by December 31, 1983.

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